SEC Comment Letter for MARA Holdings, (MARA) — Jan 11, 2018
MARA Holdings, Inc.
Date: Jan. 11, 2018 · CIK: 0001507605 · Accession: 0000000000-18-001197
AI Filing Summary & Sentiment
File numbers found in text: 001-36555
Letter
Mail Stop 4561 January 11, 2018 Francis Knuettel II Chief Financial Officer Marathon Patent Group, Inc. 11601 Wilshire Blvd., Ste. 500 Los Angeles, CA 90025
Re: Marathon Patent Group, Inc. Preliminary Infor mation Statement on Schedule 14A Filed January 2, 2018 File No. 001-36555
Dear Mr. Knuettel :
We have limited our review of your filing to those issues w e have addressed in our comment .
Please respond to this comment within ten business days by providing the requested information or advise us as soon as possible when you will respond. If you do not believe our comment applies to your facts and circumstances, please tell us why in your response.
After reviewing you r response to this comment , we may have additional comments.
General
1. Expand your descriptions of proposals nos. 1 and 2 to describe the impact of your proposed merger with Global Bitcoin Ventures on your capital structure. For example, disclose the to tal amount of shares outstanding assuming that the merger closes, and discuss whether the merger would impact the likelihood that a private placement would result in a change in control.
We urge all persons who are responsible for the accuracy and adequ acy of the disclosure in the filing to be certain that the filing includes the information the Securities Exchange Act of 1934 and all applicable Exchange Act rules require. Since the company and its management are in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
Francis Knuettel II Marathon Patent Group, Inc. January 11, 2018 Page 2
Please contact Ivan Griswold, Staff Attorney , at (20 2) 551 -3853, with any questions. If you require further assistance, you may contact t he und ersigned at (202) 551 -3730 .
Sincerely,
/s/ Jan Woo
Show Raw Text
Mail Stop 4561
January 11, 2018
Francis Knuettel II
Chief Financial Officer
Marathon Patent Group, Inc.
11601 Wilshire Blvd., Ste. 500
Los Angeles, CA 90025
Re: Marathon Patent Group, Inc.
Preliminary Infor mation Statement on Schedule 14A
Filed January 2, 2018
File No. 001-36555
Dear Mr. Knuettel :
We have limited our review of your filing to those issues w e have addressed in our
comment .
Please respond to this comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing you r response to this comment , we may have additional comments.
General
1. Expand your descriptions of proposals nos. 1 and 2 to describe the impact of your
proposed merger with Global Bitcoin Ventures on your capital structure. For example,
disclose the to tal amount of shares outstanding assuming that the merger closes, and
discuss whether the merger would impact the likelihood that a private placement would
result in a change in control.
We urge all persons who are responsible for the accuracy and adequ acy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require. Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
Francis Knuettel II
Marathon Patent Group, Inc.
January 11, 2018
Page 2
Please contact Ivan Griswold, Staff Attorney , at (20 2) 551 -3853, with any questions. If
you require further assistance, you may contact t he und ersigned at (202) 551 -3730 .
Sincerely,
/s/ Jan Woo
Jan Woo
Legal Branch Chief
Office of Information Technologies
and Services